Employee Gift Policy

The University is subject to and complies with the State Officials and Employees Ethics Act (Ethics Act) which bans University employees, their spouses, and immediate family members living with them from soliciting or accepting gifts from prohibited sources.

The Ethics Act is not intended to impact donor development activities of the University, University of Illinois Foundation, or University of Illinois Alumni Association.

The University Ethics and Compliance Office is responsible for interpreting the Ethics Act. Contact them with questions about accepting gifts at 1-866-758-2146 or by email at ethicsofficer@uillinois.edu. For additional information, visit the University Ethics and Compliance Office website.

Definition of Gifts

Gifts include any gratuity, discount, entertainment, hospitality, loan, forbearance, or other tangible or intangible item having monetary value. Gifts include, but are not limited to, cash, food and drink, and honoraria for speaking engagements related to or attributable to government and employment or the official position of an employee, member, or officer.

Definition of Employees

Employees include faculty, academic professionals, civil service workers, student workers, temporary workers, and members of the Board of Trustees. Though not compensated, Board members are considered University employees with respect to the Ethics Act.

Definition of Prohibited Source

A prohibited source is any person or entity who:

• Seeks official action by the University
• Does business or seeks to do business with the University
• Conducts activities regulated by the University
• Has interests that may be substantially affected by the performance or non-performance of the official duties of the University
• Is registered or required to be registered under the Lobbyist Registration Act (25 ILCS 170)

What to do if you Receive a Prohibited Gift

An employee who receives a gift prohibited by the Ethics Act must do one of the following:

• Return the gift to the prohibited source
• Make a monetary contribution equal to the market value of the gift to a charitable organization as defined by Section 501(c) 3 of the Internal Revenue Code (26 U.S.C. § 501(c)30)
• Give the gift itself to a charitable organization as defined by Section 501(c) 3 of the Internal Revenue Code (26 U.S.C. § 501(c)30)

Allowed Exceptions

Though the Gift Ban section of the law states employees and their family members may not solicit or accept gifts from prohibited sources, there are exceptions that do allow for acceptance of gifts. The exceptions listed below have been modified to reflect the impact of Illinois Executive Order 15-9 (January 13, 2015), which further restricts gift acceptance beyond the limitations within the Ethics Act.

1. Opportunities, benefits, and services that are available under the same conditions as for the general public
2. Anything for which the employee pays market value price
3. Any contribution that is lawfully made under the Election Code or activities associated with a fundraising event in support of a political organization or candidate
4. Educational materials and missions (training courses provided by vendors). Use of this exception must be approved in advance by the University Ethics Officer, as delegated by the Executive Director of the Executive Ethics Commission.
5. Travel expenses for meetings to discuss state business. Use of this exception must be approved in advance by the University Ethics Officer, as delegated by the Executive Director of the Executive Ethics Commission.
6. A gift from a relative
7. Anything provided by an individual on the basis of personal friendship
8. If the gift is in the form of food and/or beverage provided as a de minimis meal or refreshment at a business meeting or reception attended by the employees as part of their university responsibilities.
9. Food, refreshments, lodging, transportation, and other benefits resulting from outside business or outside employment activities of an employee's spouse
10. Bequests, inheritances, and other transfers at death
11. An intra-governmental or inter-governmental gift

There are two other exceptions within the law that were made obsolete for executive branch state agency/university employees with the signing of Executive Order 15-9 on January 13, 2015.

• Employees can no longer solicit or accept gifts from a prohibitive source, even in the cumulative value is less than $100 per calendar year, with the exception of students whose employment is a direct result of their enrollment (e.g., medical residents, student workers, graduate assistants, teaching assistants).
• Food and beverage under $75 per calendar day can no longer be accepted, with the exception of student employees whose employment is a direct result of their enrollment (e.g., medical residents, student workers, graduate assistants, teaching assistants). Only food or beverage provided as a de minimis meal or refreshment while performing official duties is permissible (see exception #8 above).

Please Note: if your department has stricter policies that would prohibit your acceptance of a gift, you must abide by the policies within your unit. University policy would supersede the law in cases where the policy is stricter.

Last Updated: July 13, 2021 | Approved: Vice President, Chief Financial Officer and Comptroller | Effective: December 2014